Case Digest (G.R. No. L-62297) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Tan Eng Kee vs. Court of Appeals and Benguet Lumber Company, G.R. No. 126881, decided October 3, 2000, petitioners Matilde Abubo and the children of the late Tan Eng Kee sued his brother Tan Eng Lay (and, after amendment, Benguet Lumber Company, represented by Lay) before the Regional Trial Court of Baguio City (Civil Case No. 1983-R) on February 19, 1990. They alleged that after World War II the brothers formed a partnership called “Benguet Lumber,” which prospered until Lay and his children in 1981 incorporated it as Benguet Lumber Company to deprive Kee and his heirs of their share of profits. The RTC, after trial, rendered judgment on April 12, 1995, declaring the enterprise a joint adventure or particular partnership, ordering accounting, the appointment of a receiver, and recognizing the heirs’ right to share in its assets. Lay appealed. On March 13, 1996, the Court of Appeals reversed and dismissed the complaint for lack of a valid partnership, and on October Case Digest (G.R. No. L-62297) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationship
- Decedent Tan Eng Kee died on September 13, 1984; his common-law spouse was Matilde Abubo, with six children (Teresita, Nena, Clarita, Carlos, Corazon, Elpidio).
- Respondent Tan Eng Lay is the decedent’s brother and president of Benguet Lumber Company, Inc.
- Pleadings and Allegations
- On February 19, 1990, petitioners (heirs of Tan Eng Kee) filed Civil Case No. 1983-R in the RTC of Baguio City for accounting, liquidation, and winding up of an alleged partnership formed after WWII between Tan Eng Kee and Tan Eng Lay.
- On March 18, 1991, petitioners amended the complaint to implead Benguet Lumber Co., Inc., alleging that in 1981 the partners converted the partnership into a corporation to deprive heirs of their share in “Benguet Lumber.”
- Trial Court Proceedings
- The RTC, on April 12, 1995, held that Benguet Lumber was a joint adventure akin to a particular partnership; it declared both brothers as partners, ordered accounting, receiver appointment, and equal division of assets; denied damages and dismissed counterclaim.
- The RTC’s decision was memorialized in its April 12, 1995 judgment.
- Court of Appeals Proceedings
- Respondent appealed; on March 13, 1996, the CA reversed the RTC, set aside its decision, and dismissed the complaint.
- Petitioners’ motion for reconsideration was denied on October 11, 1996.
- Related Criminal Proceedings
- Petitioners filed Criminal Cases Nos. 78856-78870 alleging falsification of documents (payrolls Exhs. 4–4U); on March 20, 1999, the MTC of Baguio City dismissed them for insufficiency of evidence.
- Petition for Review on Certiorari
- Petitioners brought the case to the Supreme Court under Rule 45, raising five assignments of error challenging the CA’s factual and legal findings regarding the alleged partnership.
Issues:
- Did the CA err in finding no partnership due to absence of firm account, letterheads, partnership certificate, profit-sharing agreement, and fixed duration?
- Did the CA err in relying solely on Tan Eng Lay’s testimony that Benguet Lumber was a sole proprietorship and that Tan Eng Kee was only an employee?
- Did the CA err in disregarding evidence of joint management activities (co-residence, joint supervision, price determination, supplier orders) as supporting partnership?
- Did the CA err in holding no partnership because Tan Eng Kee’s children could not identify when it began?
- Did the CA err in concluding no partnership existed despite capital exceeding ₱3,000 without a public instrument?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)